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Manahan v. ECC
GR L-44899, 22 April 1981 (104 SCRA 198)
First Division, Fernandez (p): 4 concurring.
Facts:
Maria E. Manahan, the petitioner, is the widow of Nazario
Manahan, Jr., who died of Enteric
Fever while employed as classroom teacher in Las Pias Municipal
High School, Las Pias, Rizal, on 8
May, 1975. The deceased was in perfect health when he entered
government service on 20 July 1969,
and that in the course of his employment in 1974, he was treated
for epigastric pain. He succumbed
to enteric fever on May 8, 1975. Thus, the petitioner filed a
claim with the Government Service
Insurance System (GSIS) for death benefit under Presidential
Decree 626. In a letter dated 19 June
1975, the GSIS denied the claim on a finding that the ailment of
Nazario Manahan, Jr., typhoid fever,
is not an occupational disease, and that enteric fever or
paratyphoid is similar in effect to typhoid
fever, in the sense that both are produced by Salmonella
organisms.
The petitioner appealed to the Employees Compensation Commission
(ECC), which affirmed the
decision of the GSIS on a finding that the ailment of the
deceased, enteric fever, was not induced by
or aggravated by the nature of the duties of Nazario Manahan,
Jr. as a teacher. Thus, the appeal.
Issue:
Whether the Workmens Compensation should be resolved in favor of
the workerHeld:
The Transitory and Final Provisions of the New Labor Code
provides that all actions and claims
accruing prior to the effectivity of this Code shall be
determined in accordance with the laws in force at
the time of their accrual and under the third paragraph of
Article 292, Title II (Prescription of Offenses
and Claims), workmens compensation claims accruing prior to the
effectivity of this Code and during
the period from 1 November 1974 up to 31 December 1974 shall be
processed and adjudicated in
accordance with the laws and rules at the time their causes of
action accrued Hence, this Court
applied the provisions of the Workmens Compensation Act, as
amended, on passing upon petitioners
claim.. The illness that claimed the life of the deceased may
had its onset before 10 December 1974,
thus, his action accrued before 10 December 1974. Still, In any
case, and case of doubt, the same
should be resolved in favor of the worker, and that social
legislations like the WorkmensCompensation Act and the Labor Code
should be liberally construed to attain their laudable
objective, i.e., to give relief to the workman and/or his
dependents in the event that the former should
die or sustain an injury. Pursuant to such doctrine and applying
now the provisions of the Workmens
Compensation Act in this case, the presumption of compensability
subsists in favor of the claimant.
The Supreme Court set aside the decision of the ECC and ordered
the GSIS to pay the petitioner the
amount of P6,000.00 as death compensation benefit and P600.00 as
attorneys fees, to reimburse the
petitioners expenses incurred for medical services,
hospitalization and medicines of the deceased
Nazario Manahan, Jr., duly supported by proper receipts, and to
pay administrative fees.
